Your responsibility in food safety is not only that of the product or supply leaving your facility, rather you are just as accountable for the safety of products and ingredients coming through your back door or dock(s) into your processing facility. By taking responsibility at the receiving end, you encourage effective accountability of what leaves your facility and what you advance into the food supply. The more ingredients you have full confidence in, the more confidence you will have in your final product.
This also means knowing the full supply chain of your product. One forward and one back is no longer good enough. We can expect that we will soon have to know our suppliers all the way back to the water or tree or field, but we really should already be doing so voluntarily; a finished product can never be more than the summation of its suppliers.
As such, it is important to have supplier specifications, but it is also critical to verify your suppliers’ compliance with these, making sure that all are doing what they say they are doing. The best way to do this is to periodically visit your suppliers’ facilities.
It is particularly critical to validate a supplier’s audit in person whenever possible. It is important to visit regardless, but a significant aspect of that is verifying the audit in respect to your company’s expectations and requirements. Accepting audit results at face value can give you a false sense of security, as you can sometimes find that what was acceptable for an audit is not acceptable for your specifications.
This could happen if the auditing company was auditing a different process or product. Or perhaps the supplier made temporary changes or improvements for the audit, but didn’t continue with the practices afterward. Sometimes auditors unintentionally miss what is obvious to you, with your expertise. It is difficult for them to audit everything and know every product, ingredient, process and equipment. But because missed areas or items may be critical or vital to your product or process, if you have any doubts, consider mandating a follow-up audit.
In addition, because no one knows your product or process better than you, it is important that you inspect supplier facilities, practices and processes yourself to determine if each supplier meets your expectations and needs for your product and process. We don’t always have the advantage of dictating the audit criteria, but whenever possible, try to request the specifications that best support your product or process.
Know Your Supplier.
Knowing your supply chain and the relationships that you cultivate is knowing the safety of your food. Knowing your supply chain means knowing:
- the process of the product, and the market form, including procurement, targeted pathogens, time and temperature requirements and thresholds, pathogen growth and formation requirements, packaging and storage conditions and requirements.
- the processor’s audit performance and history, any import alerts and warning letters.
- the hazards, including known contaminants and adulterants (microbiological, chemical and physical hazards), and those related to product, process, storage and distribution. Obtain letters of guarantee and research their validity; reference and research academia, industry groups and standards; design specific consortiums; and check FDA regulations and hazards guidance manuals.
- regulations related to all hazards and importation requirements (COOL, import alerts, customs requirements, permits/certificates). Be informed on recalls, warning letters and regulatory alerts, actions and postings. Sign up for email notifications from regulators and industry support groups. Research recall.gov and other Internet sites.
- critical, operational and other limits you believe important (tighter or equal to regulations) for hazards.
- product specifications and ensuring they match your product/process requirements. Ensure that they are accurate and meet or exceed regulatory and customer requirements. Have an incoming product/ingredient inspection plan and validate the accuracy of all supplier claims and labeling.
- the seven principles of HACCP in each product/process: identifying hazards, best controls, critical limits, corrective action and record-keeping; monitoring the process/product; and verifying the plan.
Visiting with your suppliers will allow you to know the answers to all the above and feel confident that the products and ingredients coming in your back door meet your and your customers’ specifications and expectations. But it will also enable you to increase your relationship with them. And relationship is critical with what you have no HACCP control over.
Explore the December 2010 Issue
Check out more from this issue and find your next story to read.
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